A Technical Analysis of Proposed Section 710
Emory University School of Law
Tax Notes, Vol. 117, p. 961, December 3, 2007
Emory Public Law Research Paper No. 07-25
In general, a partner's distributive share takes its characterization from the activities of the venture. Proposed section 710 will rechararterize as compensation the distributive share of any partner who contributes services to the partnership. It also recharacterizes as a sale certain distributions of property to a service partner. This paper examines proposed section 710 in detail and concludes that it is poorly conceived and inappropriately implemented.
Number of Pages in PDF File: 20
JEL Classification: law, tax, partnership taxAccepted Paper Series
Date posted: November 22, 2007 ; Last revised: June 19, 2012
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